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The sole issue for decision concerns the computation of the
portion of the deficiency and the accuracy-related penalty for
1994 allocable to petitioner under section 6015(d).
Background
The facts in this case have been stipulated and are found
accordingly. The stipulation of settled issues, the stipulation
of facts, and the exhibits submitted therewith are incorporated
herein by this reference.
When the petition in this case was filed, petitioner and her
husband, Robert J. Capehart (Mr. Capehart), resided in Sparks,
Nevada. Mr. Capehart died on January 23, 2002, after the
petition in this case was filed. The Estate of Robert J.
Capehart, Deceased, has been substituted as a party. Petitioner
is the personal representative of Mr. Capehart’s estate.
On April 15, 1995, Mr. Capehart and petitioner filed a joint
Federal income tax return for 1994 on which they reported the
following:
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